Clearly communicated requirements

The Chief Compliance Officer steers the application and further development of our codes and standards. He also monitors the implementation of internal and external requirements. In so doing, he is supported by our interdisciplinary Compliance and Risk Committee, the Corporate Internal Audit department, and by some 50 locally appointed compliance officers all over the world. Our corporate data protection officer is also part of our compliance organization. Together, this team coordinates the flow of information and helps our employees to implement our requirements – for example, through training courses designed to take local challenges into account. The Chief Compliance Officer reports infringements, as well as the measures taken to deal with them, directly to the Chairman of the Management Board.

Focus on communication and training

Since we operate on a global scale, our employees are confronted with a variety of legal and value systems. Many of our employees work in countries where, according to surveys by organizations such as Transparency International, there is a greater risk of encountering corrupt practices. Henkel resolutely opposes infringement of laws and standards, and rejects dishonest business practices. To impart clear rules of conduct to our employees, and especially to avoid any conflicts of interest in everyday work situations, our compliance training focuses on regular courses and communication measures. Compliance issues are addressed in seminars, employee newspapers, and special newsletters. In addition, another eleven compliance training courses were held in 2011. These took place in Bridgewater (New Jersey, USA), Budapest (Hungary), Düsseldorf (Germany), Moscow (Russia), Shanghai (China), Singapore, and Vienna (Austria).

Compliance as a management task

Our managers play a key role in regard to compliance. Given their position within the company, they bear a special responsibility to set an example for their staff. Only if our managers are seen to act in an ethically and legally impeccable manner can compliance become a guiding principle for the actions of all employees. For this reason, we have made our Compliance e-Learning program a mandatory requirement for our 9,000 managers. In 2011, almost 100 percent of them had completed the course.

Zero tolerance for violations of regulations

Improper conduct is never in Henkel's interest. It undermines fair competition and damages our trustworthiness and reputation. Not least, our employees attach great importance to a correct and ethically impeccable business environment. We react forcefully to violations of laws, codes and standards. Where necessary, we initiate appropriate disciplinary measures. In 2011, 18 employees received written warnings, and 62 contracts were terminated because of theft and fraud (42), corruption (5), violations of conduct in the marketplace / conflicts of interest (13), personal misconduct (16), and sexual harassment (4). The figures for the two preceding years lay at a similarly low level: In 2010, Henkel issued 26 written warnings and terminated 62 contracts; in 2009, there were 18 written warnings and 67 contract terminations.